MSC Surveillance Report - South African Hake Trawl Fishery

The first MSC surveillance audit for the recently certified (2010) South African Hake trawl fishery has been completed by Moody Marine Ltd. and the report is now available on the MSC website.

The assessment is for both the inshore hake fishery on Mercluccius capensis, and the offshore fishery on Merluccius paradoxus.  The offshore fishery is the more important of the two but this stock has been in a severely depleted state since the early 1970s as a result of overfishing. 

Although fisheries on both stocks obtained a score of more than 80 under each of the three MSC principles, a condition was placed under Principle 1 for the offshore hake fishery.  This condition required that there should be improvements in stock status showing trends of recovery.

The Moody Marine team based their audit on the latest assessment by MARAM (Marine Resource Assessment and Management Group).  This is the consulting company contracted by the South African government to do the assessments and develop the management strategy. 

The latest MARAM assessment is not consistent with a recovery trend in spawner biomass for the offshore stock.  Spawner biomass is only at about 60% of the estimated BMSY management target and female spawning biomass has recently shown a declining trend. 

 The Moody team suggested that the continuing low spawner biomass indicated the need to develop a new, more effective, management strategy but concluded that there was nevertheless enough evidence that a recovery was underway for the fishery to pass the audit. 

It should be noted that this stock has been managed under various different management strategies (locally called operational management procedures) developed by MARAM since 1991, but all of them have proved to be ineffective in rebuilding the stock.

The certification of the South African offshore hake fishery as sustainable by MSC in 2010 and the passing of the first surveillance audit by Moody in 2011 is misleading.  Consumers should not be fooled by the MSC eco-label applied to products from this fishery.  These products are not from a sustainably managed fishery.  South African offshore hake remains severely depleted, there is no sign of significant recovery, and the current management procedure appears to be flawed and needs to be replaced by one that may be more effective.  

Marine Stewardship Council - Acceptable time frames for rebuilding depleted fish stocks

In the fall of 2010 MSC consulted with partners and stakeholders on acceptable rebuilding timeframes for certification of depleted stocks.  MSC defines a depleted stock as one which has a biomass below BMSY (the biomass that gives maximum sustainable yield) or equivalent target level, but is still above a precautionary limit level. Fisheries on stocks which are depleted can become MSC certified, however certification of such fisheries requires that there be a rebuilding plan in place which leads to the recovery of the stock within a specified timeframe.

The MSC Fisheries Assessment Methodology addresses rebuilding under Performance Indicator PI 1.1.3.  Currently, a conditional pass score of SG60 merely requires “reasonable expectation of success” with regard to rebuilding to the target biomass of BMSY within a specified timeframe.  

An unconditional pass of SG80 requires evidence that rebuilding strategies “are rebuilding stocks, or it is highly likely based on simulation modelling or previous performance that they will be able to rebuild the stock within a specified timeframe”.

A perfect score of SG100 requires that “strategies are demonstrated to be rebuilding stocks continuously and there is strong evidence that rebuilding will be complete within the shortest practicable timeframe”.

It is good that MSC is considering revising its methodology with regard to depleted stocks; however the consultation document only addresses a clearer definition of the timeframes for rebuilding to be associated with each of the three scores.

MSC certification of fisheries on depleted stocks as “sustainable” is highly controversial.  See for example the ongoing saga of the conditional certification of the fishery on the collapsed offshore South African hake stock. 

It can be argued that the current SG100 requirement should be the minimum required in order for a fishery to be considered for a conditional pass score (SG60) and that an unconditional pass score (SG80 or 100) should only be given to a fishery on stock that has already rebuilt and is fluctuating around BMSY or above under a fishing mortality of FMSY or lower (the fishing mortality rate consistent with maintaining the stock at BMSY or above).

A fishery on a depleted stock should never be considered sustainable.   

MSC Surveillance audit – South African hake trawl fishery

It is one year into the recertification of the South African hake trawl fishery.  Moody Marine Ltd has sent a team to South Africa to undertake the first surveillance audit of the fishery as required under the MSC eco-certification procedure.

The recertification the South African hake trawl fishery was not plain sailing for Moody.  The unit of certification includes an inshore and an offshore fishery component on different species.  The offshore hake, Merluccius paradoxus, is the main contributor to the fishery.  It is in a collapsed state and did not improve during the previous certification period.

One of the independent reviewers of the Moody recertification strongly argued against calling a fishery “sustainable” when one of the components remains in a severely depleted state.  This was overruled by Moody in their assessment, but did lead to “Condition 1” in the certification – a requirement that a recovery trend be demonstrated in M. paradoxus within the certification period.

So is there evidence that M. paradoxus is recovering?  It is hard to tell.  The last public-domain stock assessment document is a 2008 paper by Rademeyer and colleagues at the MARAM consulting company based in the Mathematics Department of the University of Cape Town.  This assessment showed the spawning biomass trajectory up to 1999 and there is no evidence of rebuilding. 

The Moody 2010 certification report provides the public with a rare look at the assessment process and the state of the stock. According to the report “models developed and implemented by MCM and its contractors are subjected to various reviews and debates through MCM’s Demersal Working Group. Industry, through their consultants, participate in the debates of the Working Group and have been influential in guiding the research.”

MCM is the South African federal government department of Marine and Coastal Management.  MCM is a bit of a black hole.  Nothing in the way of useful information is released to the public.  The “contractor” to MCM is MARAM.  MARAM developed the assessment model and also carry out the assessments using the model, apparently because of a lack of quantitative expertise at MCM.  MARAM is also responsible for the development of the Operational Management Procedure which is used by MCM to manage the stock.  MARAM does not produce public documents related to its contracts with MCM.

The assessment in the Moody certification report extends the spawner biomass series to 2007.  Spawning Stock Biomass continues to decline, reaching the lowest estimated level ever.  Projections under the MARAM management procedure predict that recovery will take place following 2007, however such projected recoveries are notoriously optimistic and routinely get postponed in subsequent assessments.  There needs to be actual realized evidence of recovery to satisfy Condition 1, not merely a projection.

One assumes that the Moody team for the current hake surveillance audit will have MARAM and MCM documents at their disposal in order to evaluate whether or not Condition 1 is being met.  

There should be full public disclosure by Moody of all relevant MCM and MARAM documents on M. paradoxus used in the audit, otherwise the public are being kept in the dark and have a right to be suspicious.

Seabird feathers fly as MSC and Pew face off over swordfish and tuna

In an open letter on the MSC website, Jim Humphreys, MSC Fisheries Regional Director for the Americas, responds to the Pew Environment Group’s recent campaign to oppose the assessment of the Southeast North Atlantic swordfish, yellowfin and bigeye tuna fisheries based in Florida as sustainable.  These fisheries are currently under MSC sustainability assessment by the independent accredited certifier, MRAG Americas.

Humphries argues that previous successful MSC assessments have resulted in significant improvements in some fisheries that have dramatically reduced impacts on other species.

The idea is that MSC certifies fisheries that are not really sustainable, or that have considerable negative impacts on the ecosystem, on condition that they promise to become sustainable and reduce ecosystem impacts over the next 5 years by fixing a bunch of issues.  MSC claims that this has led to improved fisheries management. 

Humphreys picks a strange example to support his claim – the South Africa hake fishery.  The offshore hake stock, Merluccius paradoxus, the major component of the fishery, is in a collapsed state but this did not stop MSC from recently recertifying the fishery as sustainable for a second 5 year period, against the protests of one of the independent reviewers who pointed out as much.

But it is not the management of the collapsed hake stock Humphreys is referring to.  It is the reduction in seabird mortality caused by collateral damage in the hake trawl fishery through contact with the trawl and trawl warps – supposedly down from 18,000 per year a few years back to 200 per year now as a result of MSC imposed conditions on the fishery..

The 18,000 per year estimate is published in a 2008 paper in Animal Conservation (Interactions between seabirds and deep-water hake trawl gear: an assessment of impacts in South African waters by Watkins, Petersen and Ryan).

The question is, what is the basis for Humphreys’ estimate of current mortality of only 200 per year?  The number seems unlikely.

There is another story within this story. 

The president of MRAG Americas, a private, for-profit consulting company, is Andy Rosenberg, former deputy director of the National Marine Fisheries Service in the US National Oceanic and Atmospheric Administration.  Rosenberg also happens to be a Pew fellow and, according to the Gloucester Daily Times, appointed last fall by Lubchenco as a White House consultant on ocean policy.

Confusing?

More feathers may fly!

MSC eco-certified fish are not necessarily from sustainable ecosystems

An interesting posting Fishy branding - the ecosystem behind the label by Sally Campbell on the Community of Arran Seabed Trust looks behind MSC-accreditation and explores some of the emerging problems with our new hunger for ‘sustainable’ labelling.

Campbell writes "It underlines a real concern that many of the MSC eco-certified fish are not necessarily from sustainable ecosystems. Certifiers are accredited by Accreditation Services International GmbH (ASI) to the Marine Stewardship Council (MSC) Accreditation requirements. Companies such as Moody Marine Ltd and MRAG Americas, Inc can certify that fisheries meet the MSC environmental standard for sustainable fishing and these organisations duly undertake a programmed check on those fisheries wishing to have the Blue Label from MSC. It was following such a review by a these external organisations that the Cape Hake was re-certified, and the collapsed state of the fishery was even pointed out by the independent reviewer of the certification."

MSC awards re-certification to South African hake

Despite the strong objections of one of the independent reviewers, MSC has just announced that it has decided to re-certify the South African hake fishery:
http://www.msc.org/newsroom/news/south-african-hake-trawl-achieves-re-certification

The offshore hake species and main contributor to this two-species fishery is in a collapsed state and did not improve during the previous certification period.  This was clearly pointed out by the independent reviewer of the assessment but apparently ignored by MSC (see earlier post).  

The MSC website quotes a spokesman for the client group: “Initially we sought certification partly to celebrate the steady, painstaking recovery of domestic hake resources and partly because we wished to pursue a high sustainability standard for the fishery. We have seen, in the last five years, that MSC certification has other benefits: there is commercial advantage by way of access to other markets and buyers that place a premium on a certified product. Personally, the most gratifying benefit is the way in which certification motivates participants. Certification raises awareness of all fishing stakeholders about the need to adopt best practices with a view to the long term future of the hake resource.”

Painstaking recovery?
High sustainability standard for the fishery?
Do the economic benefits of certification outweigh the facts in this case?

You decide.

MSC extends certification of the South African hake trawl fishery while waiting for delayed reassessment

MSC reports on its website that there have been “unavoidable delays” in the reassessment of the South African hake trawl fishery by Moody Marine. This fishery was first certified as sustainable by MSC in 2004. http://fishyfellow.blogspot.com/2009/10/case-1-cape-hakes.html
MSC has extended certification to the end of March 2010 to allow the ecolabel to continue to hold while the reassessment is completed.

In the reassessment report on the MSC website Moody Marine gives the fishery high passing scores for all three principles and recommends recertification.

The two independent reviewers contracted by Moody were Jake Rice, who is on salary as a bureaucrat with the Canadian federal Department of Fisheries and Oceans headquarters in Ottawa, and Michael Pawson, a stock assessment scientist who recently retired from the famous Lowestoft Fisheries Laboratory.  Rice has had a number of previous MSC-related contracts - he was on the assessment team that led to the controversial certification of South Georgia Patagonian Toothfish fishery and Alaskan Pollock surveillance audits and was part of the MSC Objections Panel for the New Zealand Hoki fishery.

Reviewer A (assumed to be Rice) stated “I find no major points of disagreement with the assessment” while Reviewer B (assumed to be Pawson) found major shortcomings. He states that “I nevertheless consider that some of the marks awarded are too high particularly in relation to the stock status of M. paradoxus (which appears to be in a very depleted state) and the lack of evidence that this has been ameliorated during the certification period …I therefore question the assessment that the overall Performance of the South African Hake Trawl Fishery passes in relation to MSC Principles 1, 2 and 3, and that the fishery be certified according to the Marine Stewardship Council Principles and Criteria for Sustainable Fisheries.”

It seems unlikely that Pawson will get another MSC contract!

Pawson’s view that M. paradoxus is in a much depleted state is consistent with the published scientific literature. The fishery comprises two species, an inshore species and an offshore species. The offshore species, M paradoxus is the more important of the two in the trawl fishery. According to a report published in the African Journal of Science in 2008 by Rebecca Rademeyer and coauthors, the offshore hake stock collapsed prior to the last MSC assessment (biomass declined by more than 10% from the unfished state) and has not recovered while being managed by an “Operation Management Procedure” developed by fishery consultants at the University of Cape Town. The MSC report only admits to it being at 15% of the unfished state – nevertheless a severely depleted state.  Commonly fishery management plans assume that the biomass at 20% of the unfished state represents a precautionary approach limit reference point below which fishing should cease completely.

The hope is that a new OMP under development by consultants at the University of Cape Town will be more effective than their previous one in rebuilding the stock.   Maybe, but is that "hope" enough to certify a trawl fishery on a collapsed stock as “sustainable”?

Below are the baseline spawning biomass trajectories for the South African hake from the 2008 paper by Rademeyer